Specific jurisdiction was asserted which requires a continuous and systematic affiliation with the proposed state forum. Judge Jon S. Tigar concluded that mere awareness of Adobe’s domicile in the Northern District of California and alleged infringing conduct targeting Adobe there, was insufficient to establish specific jurisdiction. Nor was the bald assertion that Cardinal’s website was interactive and that it featured infringing Adobe products for sale adequate, even though 1.2% of Cardinal sales were shipped to California and Cardinal advertised for sale and sold infringing software on its website through its Amazon.com account.

As the sales did not aim at the forum, no special jurisdiction arose because:

Adobe does not allege that Cardinal advertises in California, markets products specifically intended for a California audience, or in any other way directs its sales activities to California.

Adobe, 2015 U.S. Dist. LEXIS 137153, at *16. Nor was leave to conduct jurisdictional discovery appropriate as it was based on purely speculative allegations of attenuated jurisdictional contacts. Upon declining jurisdiction, the case was transferred to the Eastern District of Pennsylvania.